1. INTRODUCTION‍

Sprout Care Limited, trading as Pebble, (“Pebble”, “we”, “our”, “us”) is committed to protecting and respecting your privacy. We are a private limited company established in England & Wales with a registered office at Treviot House, 186-192 High Road, Ilford, Essex IG1 1LR, and registered company number 13045499 and for the purpose of the UK General Data Protection Regulation or the UK Data Protection Act 2018 (together the “DPA”), we are the data controller.

This policy sets out the basis on which we will process any personal data in connection with: 

(a) our online marketplace (and any additional Pebble-owned or licensed technology which relates to the online marketplace) (the “Pebble Platform”), which allows parents, guardians and other individuals (“Care Seekers”) to instantly book, request to book (if not instantly available), reschedule and check the availability of certain activities, childcare and services aimed at children (the “Children’s Activities”, and providers of those activities shall be the “Providers”); 

(b) our administration portals at nursery.bookpebble.co.uk and supplier.bookpebble.co.uk (our “Admin Portals”); and

(c) our services which relate to the Pebble Platform (the “Services”). Please note that our Services continue to grow and change. Please refer to the Pebble Platform for further information about the Services we provide.

Please read this policy carefully so that you understand your rights in relation to your personal data, and how we will collect, use and process your personal data. If you do not agree with this Privacy Policy in general or any part of it, you should not access the Pebble Platform, use our Services or otherwise provide your information to us. ‍

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2. THE INFORMATION WE COLLECT‍

Information you give to us‍

You may provide the following information to us by contacting us via our Services or by Google forms, email, social media, our “contact us” page, or otherwise, by signing up for our newsletters or alerts or by creating an account with us:

• Basic contact details: Your full name, email address, phone number and home address.

• Account information: If you are using our Services as a Care Seeker, we collect your mobile number, email address and password in order to create and maintain your account with us. If you are using our Services as a user of our Admin Portals, we will instead collect your email address (which will act as the username) and password in order to create and maintain your account with us.  If you choose to use the Services and register an account, you are responsible for keeping your account credentials safe. We highly recommend that you do not share your username, password or other access details with anyone else. If you believe your account has been compromised, please contact us immediately.

• Welfare information: If you are using our Services as a Care Seeker, we collect information relating to whether you are on any welfare plans.

• Child information: If you are using our Services as a Care Seeker, we collect information relating to your child, including:
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  - General information relating to the child, including their full name (and any preferred name(s), if applicable), date of birth, home address, gender information, ethnicity information and language(s) spoken.
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  - Your relationship to the child.
  
  - Your child’s emergency contacts’ details, including each emergency contact’s full name, relationship to the child, phone number, email address, work phone number and address of workplace.
  
  - Your child’s GP or doctor details, including the GP or doctor’s full name, surgery name and contact details.
  
  - Information relating to any of your child’s health and preferences and requirements relating to administering medicine and healthcare, including dietary requirements, allergy information, accessibility information, disability information, medical consent restrictions, immunisation information, whether you have given consent for your child to be administered with certain medication (and the nature of such medicine, information on how such medicine should be administered and dosage requirements) and any other health requirements or conditions.
  
  - Preferences, requirements and instructions relating to nappy changing (if applicable).
  
  - Your child’s hobbies, interests and favourite toys.
  
  - Whether your child has additional needs or special educational needs and/or disabilities, including whether they are on an “Education, Health and Care Plan” or an “Individual Education Plan”.
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• ‍Children’s activity information: If you are using our Services as a Care Seeker, we collect information relating to the children’s activities procured by yourself on behalf of your child (including without limitation when the activities are undertaken).
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• ‍Correspondence: Any information you choose to include in communications with us, for example, when sending us an email or making a booking.

• Childcare information: If you are using our Services as a Care Seeker, we collect information relating to whether your child currently attends nursery or has attended nursery before and, if it currently attends nursery, the details of their nursery.
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• Premises information: If you are using our Services as a Care Seeker, and where you are procuring Children’s Activities from a Provider, to be delivered at a location which is not the Provider’s own residence or premises and has been chosen by yourself (including when the Provider is a babysitter or nanny who is delivering Children’s Activities at your place of residence), the premises’ address and whether there will be any pets present at such premises.
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• Admin Portals information: If you are using our Services as a user of our Admin Portals, we also collect your job title information and phone number and any information you choose to include in your communications with Care Seekers who use our Services through the “Why we cancelled your booking” functionality.

Please note that we may use a third-party payment services provider to process payment for our Services. When using a third-party payment services provider, they will store, collect and process your payment information, and our servers will not have access to your payment information.

Information we collect automatically

When you visit the Pebble Platform, we automatically collect the information sent to us by your computer, mobile phone or other access device. This information includes: (i) your IP address; (ii) device information including, but not limited to, name and type of operating system; (iii) mobile network information; and (iv) standard web information such as your browser type and the pages you access on the Pebble Platform.

Information we collect from third parties

If you are using our Services as a Care Seeker, when you sign up for an account and choose to link the nursery your child usually attends to your account on the Pebble Platform, if that nursery is a Provider, we collect information regarding the nursery room assigned to your child from that Provider.‍

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3. HOW DO WE USE YOUR INFORMATION?‍

Our lawful bases for processing your personal data

We process your personal data in order to perform our contract with you, such as:

• provide you with our Services, other content and the Pebble Platform’s functionalities;

• communicate with you about your booking or customer service enquiries;

• register and maintain your account or membership with us; and

• administer and provide Services and customer support per your request.

We obtain your consent to process your personal data for the following reasons:

• sign you up for our newsletters or alerts; 

• if you opted into marketing, to communicate with you about products, services, marketing, promotions, events and other news and information we think will be of interest to you; and

• collect information relating to your child’s medical conditions.

• collect information required by providers relating to the activities or classes you are seeking to book.

In order to be responsive to you, maintain our business relationship, improve the quality of the Services and promote the success of our business, all as a matter of legitimate interests, we will use your personal data to:

• send you announcements in relation to security, privacy or administrative related communications (these communications are not marketing orientated, and we do not rely on consent, so you may not opt out);

• personalise our Services to ensure content from the Services is presented in the most effective manner for you and your device;

• administer the Services, and for internal operations, in order to conduct troubleshooting, data analysis, testing, research, statistical and survey analysis (including analysing booking patterns);

• maintain the safety and security of our users, Services, and business; build and maintain our community; 

• improve and develop our products; and

• comply with legal obligations.

In addition, we may use all of the above information to comply with any applicable legal obligations, to enforce any applicable terms of service, and to protect or defend the Services, our rights, the rights of our users, or others.

In addition to the above, we also process your personal data to provide you with access to, and the Services provided by, the Admin Portals including:

• managing bookings (and requests for bookings) from Care Seekers and enabling you to upload the Provider’s availability; and

• communicating with Care Seekers (including regarding customer service enquiries and the reasons for cancellation of their bookings).

We process your personal data for these purposes in order to perform our contract with you.

Our application conditions for processing your special category data

Special category data includes: (i) personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership; (ii) genetic data; (iii) biometric data (where used for identification purposes); and (iv) data concerning health, a person’s sex life or a person’s sexual orientation.

Where we process your special category data, we do so:

• because you have provided your explicit consent; or

• for reasons of substantial public interest (including equality of opportunity or treatment, preventing or detecting unlawful acts, regulatory requirements, support for individuals with a particular disability or medical condition and safeguarding of children and individuals at risk).
  

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4. COOKIES‍

We use cookies to collect information about your browsing activities over time and across different websites following your use of our Services. Cookies allow us to recognise and count the number of users and to see how users move around our website when they are using it. This helps us to improve our Services and the way the Pebble Platform works. You can find more information about cookies and how to manage them here. For more information, please refer to our Cookies Policy.

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5. HOW THE COMPANY SHARES YOUR INFORMATION‍

We do not use or share your personal data to others except as described in this Privacy Policy. In certain circumstances, we also may share your information with third parties with your consent, as necessary, or as otherwise required or permitted by law. Specifically, we may share your personal data:

• With our Providers. When a booking request is made, your information will be shared with the Provider to provide our Services (i.e. to make and coordinate the booking with the Provider) and for the Provider’s own purposes, which may include marketing or advertising purposes. When we provide information to Providers, your information is provided just as it would be if you contacted the Provider or made the booking with the Provider directly. Please consult the relevant Provider’s privacy policy for details on how they process your personal data.|
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• With service providers and vendors for business purposes. Such third parties include: (i) data analytics vendors; (ii) security vendors; and (iii) website hosting vendors. These service providers receiving this information assist us with many different functions and tasks, such as providing data storage and disaster recovery services and communicating with you.
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• With our affiliates. We may share your information with companies within our corporate family.‍‍

• For legal reasons and to protect our Services and business. We may share your information in response to a legal obligation or if we have determined that it is necessary to share your personal data to comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory enquiries, protect our interests or those of our users, or exercise or defend legal claims.
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• In connection with an asset sale, merger, bankruptcy, or other business transaction. We may share your personal data while negotiating or in relation to a change of corporate control such as a restructuring, merger, or sale of our assets.
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• To enforce any applicable terms of service. We may share your personal data to enforce our terms and conditions or any other applicable terms of service.
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• To ensure our safety and security of and/or of our users. We may share your personal data if necessary to ensure our, or our users’, safety and security.
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• When you request us to share certain information with third parties. With your permission or upon your discretion, we may disclose your personal data.‍

• With professional advisors. As necessary, we may share your information with professional advisors functioning as service providers such as auditors, law firms, or accounting firms.

You acknowledge that such sharing of information may occur in all of the aforementioned circumstances and is permitted by and subject to this Privacy Policy.

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‍6.  WHERE WE STORE YOUR INFORMATION‍

The information that we collect from you will be transferred to, and stored at/processed in countries outside the United Kingdom (“UK”). Your personal data is also processed by staff operating outside the UK who work for us or one of our third party service providers or partners. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this.

For any transfers of data outside the UK, we will implement appropriate safeguards in accordance with the DPA, unless the data transfer is to a country that has been determined by the UK Information Commissioner’s Office to provide an adequate level of protection for individuals’ rights and freedoms for their personal data. For further information regarding the appropriate safeguards that we implement, you can contact us at support@bookpebble.co.uk.

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7. HOW LONG DO WE STORE YOUR PERSONAL DATA?

We will retain your information as follows:

• your account data for as long as you keep your account open or as needed to provide you with our Services;

• if you contact us, we will keep your data for 12 months after you contact us; 

• your technical usage information for 12 months; and

• data on your use of our Services is retained for 12 months. In particular, if you are a user of our Admin Portals, we retain any personal data contained in your communications with the Care Seeker regarding why the booking was cancelled for 12 months.

We will also retain and use your personal data to the extent necessary to comply with our legal obligations, resolve disputes and enforce our policies. If you stop using our Services or if you delete your account with us, we will store your information in an aggregated and anonymised format.‍

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8. YOUR RIGHTS‍

You have certain rights in relation to your personal data (some of these only apply in certain circumstances):

• Access: You have the right to access personal data we hold about you, how we use it, and who we share it with.

• Portability: You have the right to receive a copy of the personal data we hold about you and to request that we transfer it to a third party, with certain exceptions.
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• Correction: You have the right to correct any of your personal data we hold that is inaccurate.
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• Erasure: In certain circumstances, you have the right to delete the personal data we hold about you.
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• Restriction of processing to storage only: You have the right to require us to stop processing the personal data we hold about you other than for storage purposes in certain circumstances.
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• Objection: You have the right to object to our processing of your personal data.
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• Objection to marketing: You can object to marketing at any time by opting out at the bottom of our emails to you, in your preferences centre.
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• Withdrawal of consent: Where we rely on consent to process your personal data, you have the right to withdraw this consent at any time by emailing us at support@bookpebble.co.uk.

We will respond to requests to exercise those rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances). To exercise any of these rights, you can contact support@bookpebble.co.uk.

Please note that these rights are in many cases limited by law. For example, where fulfilling your request would adversely affect other individuals or our trade secrets or intellectual property, where there are overriding public interest reasons or where we are required by law to retain your personal data.

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9. SECURITY‍

Although we do our best to protect your information, we cannot guarantee the security of your information transmitted through the Pebble Platform or over email; any transmission is at your own risk.‍

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10. THIRD PARTY LINKS‍

The Pebble Platform may contain links to other online platforms operated by third parties. We do not control such other online platforms and are not responsible for their content, their privacy policies, or their use of your information. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms (such as Facebook or Twitter) may also be viewable by other users of the Pebble Platform and/or users of those third-party online platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators except as disclosed on the Pebble Platform. We expressly disclaim any and all liability for the actions of third parties, including but without limitation to actions relating to the use and/or disclosure of personal data by third parties. Any information submitted by you directly to these third parties is subject to that third party’s privacy policy.‍

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11. MODIFICATION OF THIS POLICY‍

We change our Privacy Policy from time to time. Updates to our Privacy Policy will apply only to information collected after the date of the change. We will note on our Pebble Platform when our Privacy Policy has been updated. Please check the Pebble Platform regularly for notices of changes to our Privacy Policy.‍

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12. COMPLAINTS‍

If you have complaints about how we process your personal data, please contact us at support@bookpebble.co.uk and we will respond to your request as soon as possible.

If you think we have infringed data protection laws, you can file a claim with the UK Information Commissioner’s Office.

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13.  CONTACT‍

We welcome your questions, comments, and concerns about privacy. Please send us any feedback pertaining to privacy, or any other issue at support@bookpebble.co.uk.